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by $2,258 for wage expense under sec. 45A.
Furthermore, respondent allowed a credit against
petitioners’ tax in the amount of $2,258 for the
Indian employment credit. Petitioners had
requested this credit in a claim for a refund
submitted to respondent. Respondent did not allow
any other portion of the claimed refund.
Petitioner did not address these amounts at trial
or on brief, and we deem petitioners to have
conceded these adjustments.
III. Docket No. 5508-99, Eddie Cordes, Inc., Successor by Merger
with Cordes Finance Corp.:
A. 1994:
1. The parties previously agreed to increase taxable
income for bad debt expenses and bad debts charged
to income. The parties also previously agreed to
decrease taxable income to reflect an interest
expense payment made to John Cordes, Inc.
2. Respondent increased petitioner’s taxable income
by $8,564 to reflect additional gross receipts
(described in the notice of deficiency as “Gross
Receipts – Debit to Income). Respondent concedes
this adjustment.
3. Respondent increased petitioner’s taxable income
by $86,160 to reflect additional gross receipts
(described in the notice of deficiency as “Gross
Receipts – Credits to Retained Earnings). The
parties stipulated instead to increase taxable
income by $66,560.
4. Petitioner concedes respondent’s determination
increasing taxable income by $10,380 to reflect
bad debt recoveries.
5. Respondent increased petitioner’s taxable income
by $131,020 to reflect income from misposted
receipts. The parties stipulated instead to
increase taxable income by $43,673.
6. Petitioner concedes respondent’s determination
increasing taxable income by $71,910 to reflect
income from unbooked receipts.
7. Petitioner concedes respondent’s determination
increasing taxable income by $88,225 to reflect
payments on unidentified loans.
8. Respondent increased petitioner’s taxable income
by $405,724 to reflect income from unidentified
sources. The parties stipulated instead to
increase taxable income by $45,702.
B. 1995:
1. The parties previously agreed to increase taxable
income for bad debt expenses, bad debts charged to
income, and due to a disallowed net operating loss
carryover from 1994. The parties also previously
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